American Bar Endowment
Effective Date: April 30, 2019
I. Introduction: Our Primary Goal -- Your Privacy
For California residents, please consult Section VIII “California Privacy Rights” for additional considerations.
III. Website Terms
IV. Types of Data We Collect
The types of Personal Data we collect include, but are not limited to:
- General data (e.g., names, dates of birth, home and business addresses, email addresses, telephone numbers, height and weight estimates, marital status, and family member information that is provided by our members/insureds);
- Government-issued identification numbers (e.g., social security numbers);
- Financial information (e.g., routing numbers, Certificate Holder ID numbers, and billing numbers as further described below);
- Your transactions with us and payment records (such as policy coverages, premium payments, payment status and history);
- Information received from the American Bar Association (ABA) for the ABE’s use in promoting insurance plans to ABE members; and
- Other identification information.
Insurance Premium Payments. To make insurance premium payments through the Site, you must submit your Certificate Holder ID Number and Bill Number. All payment information is hosted by our third-party payment processor Harris Bank. The HPE Web Data Protection and Privacy Statement (https://www.paybill.com/Privacy%20Statement.htm) can be consulted for additional information. All payments are sent to and processed by our third party payment processor Harris Bank and we receive information regarding payment status from them. While we do not directly access, handle, or store your credit or debit card or payment information, we may keep a record of your payments. We may store your Certificate Holder ID Number and Billing Number to facilitate billing payments and we may collect related Personal Data, such as your name and contact information, to facilitate the applicable transaction.
We may collect and store information that does not directly identify you as you interact with our Site, Insurance Specialists, or promotional material (“Non-Personal Data”). The types of Non-Personal Data we collect include, but are not limited to: your Internet protocol (“IP”) address, geolocation, type of browser, operating system, search requests, website traffic information, the date and time you visited our Site, the amount of time you used the Site, the pages you visited on our Site, any device you are using to access the Site, the Site you visited after leaving our Site, and any hyperlinks you click on when using the Site.
- De-Identified Data. Any Personal Data that has been de-identified and/or aggregated so that it no longer contains Personal Data and will be treated as Non-Personal Data (for example, test answers and test results).
- IP Address and Geolocation. IP address and geolocation will be treated as Non-Personal Data except in locations where otherwise required by applicable law.
- ABE is the sole and exclusive owner of any Non-Personal Data received by ABE or its third-party service providers or licensors through your use of the Site, cookies, web beacons or anything similar.
V. How We Use Your Data
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below.
Service Communications. We may use Personal Data for the purposes of communicating services, such as billing reminders and customer service messages.
As Stated or Agreed to at the Point of Collection. We may use Personal Data for the purposes stated or agreed to (or as is obvious) at the point of collection. For example, we use Personal Data to provide insurance plan information you request or that we think you may be interested in and to answer your questions, comments, or complaints. We may also use Personal Data as requested or consented to by you.
Charitable Gift Accounts, Opportunity Grants, and Dividend Donations. We may use Personal Data for the purposes of establishing a Charitable Gift account, to apply for an Opportunity Grant, and for members to donate any available dividends to ABE.
Administration. We may use Personal Data for administrative purposes, such as managing your accounts, facilitating transactions, to inform you of our business strategies, to understand the Site’s demographics and user preferences, for evaluating applications, and managing profiles. In addition, we may use Personal Data in the aggregate to help us better serve our insureds.
Site Management. We may use Personal Data for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site for you and our users.
To Protect Our Rights. We may use Personal Data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Data to seek any business, financial or legal advice, and to respond to other legal requests.
Analytics. The Site may use third-party analytics tools to collect and process data about your use of the Site, including when you visit the Site, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we may use to improve the Site’s structure and content.
Online Behavioral Advertising. We may occasionally use advertising networks and services provided by third-party vendors. These services collect data about your interactions with the Site and other websites across the Internet and use such data to target personal content and advertisements for goods and services. The data collected may be associated with your Personal Data. The targeted content and advertisements may appear on the Site and on other websites and may be sent to you via email. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests.
VI. How We Share Your Data
We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways and in compliance with applicable laws, including but not limited to:
- Employees and Affiliates. We may share Personal Data with our employees and affiliates who have a need to know the information for our business purposes.
- Our Affiliated Insurance Companies and Regulatory Agencies. In the course of providing insurance, we may share Personal Data with our affiliated insurance companies and parties who perform an insurance function for ABE. For example, we may provide New York Life with information confirming your insurance premium has been received for a specific period of time and communicate with insurance regulatory agencies in connection with the regulation of our business.
- Third-Party Service Providers. We may share data with third parties to fulfill service requests and to perform business functions for our third-party service providers, suppliers, consultants, agents, resellers, partners and representatives (collectively, “Service Providers”). For example, the ABE contracts with Service Providers on our behalf such as mailing and delivering services, and customer support. In addition, we may share Personal Data with Service Providers to help us host and manage the Site; provide targeted advertising and other marketing; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide premium services; provide public relations; provide learning management systems; provide email services; provide data processing; and provide the security of the Site.
- Government Officials / Law Enforcement. We may share data with third parties as required by law or to protect the ABE in the good-faith belief that such action is necessary to conform to legal requirements or comply with legal process served on the ABE; to protect and defend the ABE’s rights or property; or protect the personal safety of ABE personnel, members, or members of the public in appropriate circumstances.
- Change in Ownership. In the event the ABE is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Data to the subsequent owner(s).
- We may share Personal Data with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Your email address will be used only by the ABE and ABE vendors performing member services. Any information that you provide to us or that we obtain about you, will not be sold, rented, leased, or given to a non-affiliated third party without your consent.
ABE may collect, use, share, transfer and otherwise process Non-Personal Data received or created by ABE (or its Service Providers) for any business purposes in its sole discretion, in compliance with applicable laws.
VII. How You Can Manage the Processing of Your Data
ABE sends out two types of email – promotional information on available insurance plans and emails of a more administrative nature highlighting plan changes and enhancements. You may opt out of receiving either or both types of email by contacting us and requesting that your name and email address be removed from any email lists utilized for those purposes. For California residents, please consult the next section for additional considerations.
VIII. California Privacy Rights
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
We are committed to protecting children’s privacy. We do not knowingly collect, use, or share Personal Data from, or promote to, children under the age of 18. If a parent or legal guardian learns that their child provided us Personal Data without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Data.
X. How We Protect Personal Data
YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.
XI. Linking to Other Internet Sites and Third-Party Websites
XII. Cookies and Other Tracking Web Devices
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
- make our Site function properly;
- provide personalized experiences;
- tailor our interactions with you;
- help with our marketing efforts;
- provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
- help us improve our services.
What type of information do Cookies collect? The Cookies on our Site may collect information such as:
- IP addresses assigned to the computers and other devices you use;
- your internet service provider;
- device ID number;
- approximate geographic location;
- browser type;
- Site pages visited;
- websites you access before and after visiting the Site, and
- data related to how and when you use the Site.
We may combine information from Cookies with other Collected Data (including Personal Data) and data obtained from third parties.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Flash cookies differ from other browser cookies regarding the amount and types of data collected and how the data is stored. Your browser will not remove and cannot manage Flash cookies in the same way as other Cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.
How do we treat information gathered by Cookies? We will treat information gathered by Cookies as Non-Personal Data unless otherwise required by applicable law.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
XIII. Social Media
We are active on social media, including Facebook, Twitter, and LinkedIn (“Social Media”). You may comment on Social Media regarding ABE and our products and services.
Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and on our Social Media pages any comments or content that you post on our Social Media pages. You agree to hold ABE harmless and without liability for the results of any and all content you post on ABE’s social media.
Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
The Site may use advertising networks and services offered by Social Media to deliver advertising content. Use of these services requires Social Media to implement cookies or pixel tags to deliver ads to you while you access the Site.
XIV. Governing Law
XV. Access from Outside the United States
This Site is operated and maintained by ABE from the United States and is intended solely for a United States audience. If you access the Site from outside the United States, please be aware that Collected Data may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Data in the United States to be equivalent to that required by the authorities in other jurisdictions.
XVI. Breach Notification
We use commercially reasonable technical and organizational measures to help secure Personal Data against loss, misuse, and alteration appropriate to the type of Personal Data processed. In the event we determine that there has been a data security incident, we will notify you of the incident by email, U.S. mail, telephone, or other means if required under applicable law.
XVII. Contact Information
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change or remove your Personal Data, please contact us as indicted below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.
American Bar Endowment
321 North Clark Street
Chicago, IL 60654
(800) 621-8981 or (312) 988-6400